Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
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